This article examines the diverted profits tax
(DPT) introduced by the United Kingdom to
counter aggressive tax planning adopted by
many multinational enterprises so as to transfer
profits from its jurisdiction, and the main
controversies surrounding the compatibility of
the DPT with tax treaties.
Prevention of hybrid mismatches as a justificationRamon Tomazela
This document discusses the European Union's justification for preventing hybrid mismatches as a way to tackle cross-border tax arbitrage. It begins by explaining how differences in tax rules between jurisdictions create opportunities for taxpayers to engage in tax planning strategies that exploit these differences. Specifically, hybrid mismatch arrangements can result in double deductions, deduction without inclusion, or excessive foreign tax credits. The EU has taken steps through the Parent-Subsidiary Directive and BEPS project to eliminate double non-taxation from these arrangements. The document then analyzes how hybrid mismatches can hamper the objectives of the single market by resulting in significant lost tax revenue and creating an uneven playing field for companies.
Bulletin source versus residence - jfb and rtsRamon Tomazela
This document summarizes an article that discusses the dichotomy between source and residence taxation in international taxation and tax treaties. It notes that some developed countries have started taxing profits of multinational enterprises from exploiting their consumer markets, even without a permanent establishment. Meanwhile, developing countries argue that source states should tax technical service payments to prevent erosion of their tax bases. The document outlines how Article 7 of tax treaties allocates taxing rights and the concept of permanent establishment. It discusses the challenges posed by the source vs residence dichotomy as business models have evolved with globalization and technology changes.
Poland is located in Central Europe and borders several countries. Its capital is Warsaw and its official language is Polish. There are various taxes in Poland's taxation system, including corporate income tax of 19%, personal income tax with rates from 18-32%, VAT with standard and reduced rates, transaction tax on certain civil law transactions, and real estate tax. Foreign investors can acquire Polish real estate by asset deal or share deal and must follow various rules depending on their country of origin.
As with previous years, our tax experts have prepared a comprehensive yet brief overview of taxation in Hungary.
Our material shall provide you with the necessary information about Hungarian business environment and its statutory framework, therefore we encourage you to pay close attention.
Compartilho o artigo escrito em coautoria com Ramon Tomazela Santos no qual abordamos um panorama geral sobre preços de transferência no Brasil, publicado em "The Transfer Pricing Law Review - Steve Edge and Dominic Robertson (Ed.)". Confira a íntegra:
Legislative measures with significant impact in certain industry sectors introduced by the Government Emergency Ordinance No. 114/ 2018 implementing measures in the field of public investments and fiscal-budgetary measures, amending and supplementing normative acts and extending certain deadlines.
Download our "2017 Transfer Pricing Overview for Hungary" for more information or simply contact our experts in Hungary if you need any additional support!
This document summarizes tax rates and policies across several European Union countries. It finds that most EU countries have progressive income tax rates between 40-50% for the highest incomes. Many countries provide tax allowances for families. There have been tax cuts and increases in tax-free thresholds in some countries in recent years. Social security contribution rates average 30-40% of income. Retirement ages are gradually increasing to 65-67 years old across Europe. Indirect taxes like VAT make up about 30-50% of total tax revenues depending on the country.
Prevention of hybrid mismatches as a justificationRamon Tomazela
This document discusses the European Union's justification for preventing hybrid mismatches as a way to tackle cross-border tax arbitrage. It begins by explaining how differences in tax rules between jurisdictions create opportunities for taxpayers to engage in tax planning strategies that exploit these differences. Specifically, hybrid mismatch arrangements can result in double deductions, deduction without inclusion, or excessive foreign tax credits. The EU has taken steps through the Parent-Subsidiary Directive and BEPS project to eliminate double non-taxation from these arrangements. The document then analyzes how hybrid mismatches can hamper the objectives of the single market by resulting in significant lost tax revenue and creating an uneven playing field for companies.
Bulletin source versus residence - jfb and rtsRamon Tomazela
This document summarizes an article that discusses the dichotomy between source and residence taxation in international taxation and tax treaties. It notes that some developed countries have started taxing profits of multinational enterprises from exploiting their consumer markets, even without a permanent establishment. Meanwhile, developing countries argue that source states should tax technical service payments to prevent erosion of their tax bases. The document outlines how Article 7 of tax treaties allocates taxing rights and the concept of permanent establishment. It discusses the challenges posed by the source vs residence dichotomy as business models have evolved with globalization and technology changes.
Poland is located in Central Europe and borders several countries. Its capital is Warsaw and its official language is Polish. There are various taxes in Poland's taxation system, including corporate income tax of 19%, personal income tax with rates from 18-32%, VAT with standard and reduced rates, transaction tax on certain civil law transactions, and real estate tax. Foreign investors can acquire Polish real estate by asset deal or share deal and must follow various rules depending on their country of origin.
As with previous years, our tax experts have prepared a comprehensive yet brief overview of taxation in Hungary.
Our material shall provide you with the necessary information about Hungarian business environment and its statutory framework, therefore we encourage you to pay close attention.
Compartilho o artigo escrito em coautoria com Ramon Tomazela Santos no qual abordamos um panorama geral sobre preços de transferência no Brasil, publicado em "The Transfer Pricing Law Review - Steve Edge and Dominic Robertson (Ed.)". Confira a íntegra:
Legislative measures with significant impact in certain industry sectors introduced by the Government Emergency Ordinance No. 114/ 2018 implementing measures in the field of public investments and fiscal-budgetary measures, amending and supplementing normative acts and extending certain deadlines.
Download our "2017 Transfer Pricing Overview for Hungary" for more information or simply contact our experts in Hungary if you need any additional support!
This document summarizes tax rates and policies across several European Union countries. It finds that most EU countries have progressive income tax rates between 40-50% for the highest incomes. Many countries provide tax allowances for families. There have been tax cuts and increases in tax-free thresholds in some countries in recent years. Social security contribution rates average 30-40% of income. Retirement ages are gradually increasing to 65-67 years old across Europe. Indirect taxes like VAT make up about 30-50% of total tax revenues depending on the country.
The document summarizes recent changes to UK taxation of carried interest for non-domiciled individuals working in asset management. Key points include:
- New rules since 2015 remove some tax protections for carried interest, subjecting more of it to UK tax. Carried interest may be taxed as income up to 47% rather than capital gains.
- Legislation differentiates between carried interest from funds held over 40 months versus shorter periods, and employment-related versus other structures.
- From 2017, non-doms deemed UK domiciled after 15+ years will pay UK tax on worldwide income and gains, eliminating remittance basis protections.
- US citizens face potential double taxation as carried interest
BEPS filing requirements for multinationals under country by country reportingPaul Authachinda
BEPS FILING REQUIREMENTS FOR MULTINATIONALS UNDER COUNTRY BY COUNTRY REPORTING. An MNE’s CbC report should include detailed financial and tax information
relating to the global allocation of its income and taxes. CbCR is required where the ultimate parent company has its tax residence.
Germany provides several incentives for investment including a central location, skilled workforce, and a 15% corporate tax rate. The most common legal business structure is a GmbH, which offers limited liability. Germany has a comprehensive social security and labor system where both employers and employees contribute monthly. Taxes include a solidary surcharge, trade tax, personal income tax, VAT, inheritance/gift tax, and real estate transfer tax.
The document discusses the concept of beneficial ownership and its application in international tax law. It provides examples showing how the definition of beneficial ownership has been applied differently in common law versus civil law systems, and also differently across jurisdictions. Specifically, a Canadian court defined beneficial ownership based on control and economic benefits, while a Spanish court disregarded the existence of a Dutch parent company in favor of looking at economic substance in Spain. The document argues these interpretations fail to respect EU law principles of freedom of establishment and movement between member states.
Goods and services are tangible and intangible items produced and purchased to fulfill consumer needs. Goods are physical products while services are intangible support. The Goods and Services Tax (GST), also known as Value Added Tax (VAT) in the Philippines, is a 12% sales tax collected on most sales and imports. RA 9337 expanded VAT coverage to previously untaxed items and services. While it generates government revenue, critics argue it disproportionately burdens the poor. Both costs and benefits must be considered in evaluating its impact.
The document reports on Serbia's progress towards fulfilling the criteria for EU membership. It finds that while Serbia has made some progress, there are still significant issues that need to be addressed, particularly regarding the functioning of democratic institutions and the rule of law. Political divisions have deepened and opposition parties have boycotted parliamentary sessions. Urgent reforms are needed to address issues with elections and ensure freedom of the media. Corruption remains prevalent and the judiciary needs further reform. Continued work is also needed on normalizing relations with Kosovo and aligning legislation with the EU acquis.
The document discusses excise taxes, which are taxes imposed on goods produced within a country. It provides details about the different types of excise taxes in India, including basic excise duty, additional duty, and special duty. The document also discusses the history of excise taxes in various periods in the US, including the Revolutionary War, War of 1812, Civil War, and 20th century. It provides examples of other types of indirect taxes like taxes on fuel, tobacco, alcohol, VAT, tariffs, and fees. In the end, it mentions that the Indian government is considering hiking the general excise duty rate from 10% to 12%.
This document outlines the syllabus for a public finance course. It covers 5 units: (1) introduction to public finance; (2) sources of public funds through taxes and loans; (3) principles of public expenditure and debt; (4) public finance in India; and (5) financial institutions and budgeting. Key concepts discussed include the principle of maximum social advantage, sources of revenue for central and state governments in India, and the roles of the central/union and state governments in public finance.
Australia's tax system has evolved significantly over the 20th century. At Federation in 1901, the main taxes were customs and excise duties which funded the new federal government. During World War 2, income taxes were consolidated under the federal government to increase revenue. Since the 1970s, there has been a gradual broadening of the tax base through measures like introducing capital gains tax and fringe benefits tax. The modern Australian tax system relies more heavily on direct taxation compared to the indirect duties of the early 20th century.
ALBANIA Chinese citizens excluded from Type C Visa regime
Fiscal package 2020 in Albania
Tax Procedures in Albania 2020
Value Added Tax 2020
Albania Personal And Profit Tax 2020
Albania National Taxes 2020
ALBANIA TAX FREE Real Estate Donation to Family Members 2020
The document discusses debarment of companies from public contracts in the European Union. It provides context on the development of debarment and the issues it presents. It then summarizes the key aspects of the new EU Public Procurement Directives implemented in 2014, including strengthened mandatory grounds for exclusion/debarment such as conviction for corruption, fraud, or other criminal offenses. The directives aim to increase transparency and prevent conflicts of interest in public procurement through measures like mandatory reporting of violations and record keeping of high-value contracts.
WIRC - Planning Investments through various jurisdictions - Cyprus presentati...P P Shah & Associates
The document summarizes a presentation on planning inbound and outbound investments through various jurisdictions, with a focus on analyzing Cyprus and Mauritius as holding company jurisdictions. Key points covered include an overview of international tax planning, designing offshore plans, analyzing Cyprus's tax advantages for holding companies including no dividend withholding taxes or capital gains taxes, and comparing the tax treatments between Cyprus and other jurisdictions like India, Russia, UK, and China. Mauritius is also analyzed as a potential holding company jurisdiction.
- The document summarizes recent tax law developments in the European Union. Key points include:
- EU Member States agreed on rules to tackle "hybrid mismatches" between tax structures of EU and non-EU countries. This will impact many existing corporate structures.
- The Netherlands Supreme Court referred preliminary questions to the EU Court of Justice regarding whether denying refunds of dividend withholding tax to non-resident investment funds discriminates against them compared to Dutch funds.
- The EU Court of Justice ruled that a non-resident individual receiving 60% of income in the Netherlands should be allowed to deduct losses from a property in their country of residence, Spain, from their Dutch taxable income.
Grant Thornton Hungary Tax News - November 2014 en (2)Alex Baulf
Tax Service News from Grant Thornton Hungary:
Grant Thornton Hungary would like to call your attention to the most important tax law changes. Most of the changes will enter into force by 1 January 2015. We indicate separately, if legislation enters into force at a different date.
The information provided herein is of general nature and is based on facts subject to change. Such information may not be regarded and therefore in no way interpreted as accountancy, legal or taxation advice provided to the reader by Grant Thornton Hungary. These materials are not aimed at complying with particular scenarios and to be suitable for application in certain situations, therefore the consideration of certain taxation law and other factors not
discussed herein may be necessary. With regard to this – should you resolve upon any action whatsoever based on the information provided herein – it is recommended to establish contact with Grant Thornton Hungary or other taxation specialists. Amendments of the taxation laws and other factors may influence the contents communicated herein – in certain cases even with retroactive effect. Grant Thornton Hungary assumes no responsibility of informing the readers of these changes.
Vat revenue and state investment spending in nigeria, 1994 2010.Alexander Decker
This study examines the relationship between VAT revenue and state investment spending in Nigeria from 1994 to 2010. Time series data on VAT revenue and state investment expenditure were collected from the Central Bank of Nigeria. Unit root tests and cointegration analysis were conducted to determine the long-run relationship between the variables. Vector error correction modeling was also used to analyze the causal link between VAT revenue and state investment spending. The results showed there is a long-run bidirectional causal relationship between the two variables, indicating they influence each other both in the short-run and long-run.
Douglas Elmendorf, director of the Congressional Budget Office, testified before the Senate Finance Committee about trends in federal tax revenues and rates. Under current law, revenues are projected to rise to 21% of GDP by 2020 as tax cuts expire, but spending is also projected to rise and deficits will remain between 2.6-3.0% of GDP. Taxes affect economic activity through marginal tax rates and tax expenditures. Tax expenditures subsidize certain activities but reduce tax revenues. The tax burden is progressive, with higher-income households paying a larger share of their income in taxes.
The new Accountancy Act (AA) in Bulgaria introduces several changes effective January 1, 2016, including categorizing entities based on size, redefining public interest entities, allowing more entities to prepare financial statements using National Accounting Standards, and requiring new annual reports. It also increases financial statement publication and audit requirements, clarifies management responsibilities, and imposes higher penalties for noncompliance.
The document provides an overview and summary of Michigan's state tax revenue for FY 2017-2018, including explanations of key terms, descriptions of major state taxes, recently enacted tax changes, and revenue projections. It discusses the individual income tax, sales tax, use tax, tobacco taxes, business taxes, and state property taxes. Recently enacted changes include exempting more commercial and industrial personal property from taxes and establishing the Local Community Stabilization Authority to levy use taxes to reimburse local governments for lost property tax revenue.
Este documento fornece instruções sobre como usar o SlideShare para fazer upload e publicar apresentações online, incluindo acessar o site, fazer upload de arquivos, escolher uma categoria, copiar o código embed para publicar no blog e concluir a publicação.
The document summarizes recent changes to UK taxation of carried interest for non-domiciled individuals working in asset management. Key points include:
- New rules since 2015 remove some tax protections for carried interest, subjecting more of it to UK tax. Carried interest may be taxed as income up to 47% rather than capital gains.
- Legislation differentiates between carried interest from funds held over 40 months versus shorter periods, and employment-related versus other structures.
- From 2017, non-doms deemed UK domiciled after 15+ years will pay UK tax on worldwide income and gains, eliminating remittance basis protections.
- US citizens face potential double taxation as carried interest
BEPS filing requirements for multinationals under country by country reportingPaul Authachinda
BEPS FILING REQUIREMENTS FOR MULTINATIONALS UNDER COUNTRY BY COUNTRY REPORTING. An MNE’s CbC report should include detailed financial and tax information
relating to the global allocation of its income and taxes. CbCR is required where the ultimate parent company has its tax residence.
Germany provides several incentives for investment including a central location, skilled workforce, and a 15% corporate tax rate. The most common legal business structure is a GmbH, which offers limited liability. Germany has a comprehensive social security and labor system where both employers and employees contribute monthly. Taxes include a solidary surcharge, trade tax, personal income tax, VAT, inheritance/gift tax, and real estate transfer tax.
The document discusses the concept of beneficial ownership and its application in international tax law. It provides examples showing how the definition of beneficial ownership has been applied differently in common law versus civil law systems, and also differently across jurisdictions. Specifically, a Canadian court defined beneficial ownership based on control and economic benefits, while a Spanish court disregarded the existence of a Dutch parent company in favor of looking at economic substance in Spain. The document argues these interpretations fail to respect EU law principles of freedom of establishment and movement between member states.
Goods and services are tangible and intangible items produced and purchased to fulfill consumer needs. Goods are physical products while services are intangible support. The Goods and Services Tax (GST), also known as Value Added Tax (VAT) in the Philippines, is a 12% sales tax collected on most sales and imports. RA 9337 expanded VAT coverage to previously untaxed items and services. While it generates government revenue, critics argue it disproportionately burdens the poor. Both costs and benefits must be considered in evaluating its impact.
The document reports on Serbia's progress towards fulfilling the criteria for EU membership. It finds that while Serbia has made some progress, there are still significant issues that need to be addressed, particularly regarding the functioning of democratic institutions and the rule of law. Political divisions have deepened and opposition parties have boycotted parliamentary sessions. Urgent reforms are needed to address issues with elections and ensure freedom of the media. Corruption remains prevalent and the judiciary needs further reform. Continued work is also needed on normalizing relations with Kosovo and aligning legislation with the EU acquis.
The document discusses excise taxes, which are taxes imposed on goods produced within a country. It provides details about the different types of excise taxes in India, including basic excise duty, additional duty, and special duty. The document also discusses the history of excise taxes in various periods in the US, including the Revolutionary War, War of 1812, Civil War, and 20th century. It provides examples of other types of indirect taxes like taxes on fuel, tobacco, alcohol, VAT, tariffs, and fees. In the end, it mentions that the Indian government is considering hiking the general excise duty rate from 10% to 12%.
This document outlines the syllabus for a public finance course. It covers 5 units: (1) introduction to public finance; (2) sources of public funds through taxes and loans; (3) principles of public expenditure and debt; (4) public finance in India; and (5) financial institutions and budgeting. Key concepts discussed include the principle of maximum social advantage, sources of revenue for central and state governments in India, and the roles of the central/union and state governments in public finance.
Australia's tax system has evolved significantly over the 20th century. At Federation in 1901, the main taxes were customs and excise duties which funded the new federal government. During World War 2, income taxes were consolidated under the federal government to increase revenue. Since the 1970s, there has been a gradual broadening of the tax base through measures like introducing capital gains tax and fringe benefits tax. The modern Australian tax system relies more heavily on direct taxation compared to the indirect duties of the early 20th century.
ALBANIA Chinese citizens excluded from Type C Visa regime
Fiscal package 2020 in Albania
Tax Procedures in Albania 2020
Value Added Tax 2020
Albania Personal And Profit Tax 2020
Albania National Taxes 2020
ALBANIA TAX FREE Real Estate Donation to Family Members 2020
The document discusses debarment of companies from public contracts in the European Union. It provides context on the development of debarment and the issues it presents. It then summarizes the key aspects of the new EU Public Procurement Directives implemented in 2014, including strengthened mandatory grounds for exclusion/debarment such as conviction for corruption, fraud, or other criminal offenses. The directives aim to increase transparency and prevent conflicts of interest in public procurement through measures like mandatory reporting of violations and record keeping of high-value contracts.
WIRC - Planning Investments through various jurisdictions - Cyprus presentati...P P Shah & Associates
The document summarizes a presentation on planning inbound and outbound investments through various jurisdictions, with a focus on analyzing Cyprus and Mauritius as holding company jurisdictions. Key points covered include an overview of international tax planning, designing offshore plans, analyzing Cyprus's tax advantages for holding companies including no dividend withholding taxes or capital gains taxes, and comparing the tax treatments between Cyprus and other jurisdictions like India, Russia, UK, and China. Mauritius is also analyzed as a potential holding company jurisdiction.
- The document summarizes recent tax law developments in the European Union. Key points include:
- EU Member States agreed on rules to tackle "hybrid mismatches" between tax structures of EU and non-EU countries. This will impact many existing corporate structures.
- The Netherlands Supreme Court referred preliminary questions to the EU Court of Justice regarding whether denying refunds of dividend withholding tax to non-resident investment funds discriminates against them compared to Dutch funds.
- The EU Court of Justice ruled that a non-resident individual receiving 60% of income in the Netherlands should be allowed to deduct losses from a property in their country of residence, Spain, from their Dutch taxable income.
Grant Thornton Hungary Tax News - November 2014 en (2)Alex Baulf
Tax Service News from Grant Thornton Hungary:
Grant Thornton Hungary would like to call your attention to the most important tax law changes. Most of the changes will enter into force by 1 January 2015. We indicate separately, if legislation enters into force at a different date.
The information provided herein is of general nature and is based on facts subject to change. Such information may not be regarded and therefore in no way interpreted as accountancy, legal or taxation advice provided to the reader by Grant Thornton Hungary. These materials are not aimed at complying with particular scenarios and to be suitable for application in certain situations, therefore the consideration of certain taxation law and other factors not
discussed herein may be necessary. With regard to this – should you resolve upon any action whatsoever based on the information provided herein – it is recommended to establish contact with Grant Thornton Hungary or other taxation specialists. Amendments of the taxation laws and other factors may influence the contents communicated herein – in certain cases even with retroactive effect. Grant Thornton Hungary assumes no responsibility of informing the readers of these changes.
Vat revenue and state investment spending in nigeria, 1994 2010.Alexander Decker
This study examines the relationship between VAT revenue and state investment spending in Nigeria from 1994 to 2010. Time series data on VAT revenue and state investment expenditure were collected from the Central Bank of Nigeria. Unit root tests and cointegration analysis were conducted to determine the long-run relationship between the variables. Vector error correction modeling was also used to analyze the causal link between VAT revenue and state investment spending. The results showed there is a long-run bidirectional causal relationship between the two variables, indicating they influence each other both in the short-run and long-run.
Douglas Elmendorf, director of the Congressional Budget Office, testified before the Senate Finance Committee about trends in federal tax revenues and rates. Under current law, revenues are projected to rise to 21% of GDP by 2020 as tax cuts expire, but spending is also projected to rise and deficits will remain between 2.6-3.0% of GDP. Taxes affect economic activity through marginal tax rates and tax expenditures. Tax expenditures subsidize certain activities but reduce tax revenues. The tax burden is progressive, with higher-income households paying a larger share of their income in taxes.
The new Accountancy Act (AA) in Bulgaria introduces several changes effective January 1, 2016, including categorizing entities based on size, redefining public interest entities, allowing more entities to prepare financial statements using National Accounting Standards, and requiring new annual reports. It also increases financial statement publication and audit requirements, clarifies management responsibilities, and imposes higher penalties for noncompliance.
The document provides an overview and summary of Michigan's state tax revenue for FY 2017-2018, including explanations of key terms, descriptions of major state taxes, recently enacted tax changes, and revenue projections. It discusses the individual income tax, sales tax, use tax, tobacco taxes, business taxes, and state property taxes. Recently enacted changes include exempting more commercial and industrial personal property from taxes and establishing the Local Community Stabilization Authority to levy use taxes to reimburse local governments for lost property tax revenue.
Este documento fornece instruções sobre como usar o SlideShare para fazer upload e publicar apresentações online, incluindo acessar o site, fazer upload de arquivos, escolher uma categoria, copiar o código embed para publicar no blog e concluir a publicação.
LinkedIn Quiz: Which Parent Are You When It Comes to Helping Guide Your Child...LinkedIn
Lighthouse, Helicopter or Free-range? Take this quiz to find out what your parenting style is when your children have flown the nest and started their career.
Join LinkedIn's Bring In Your Parents Day on November 5 -- learn out more at biyp.linkedin.com or join the social conversation using #BIYP.
I don't always feel like a wizard. Like many of you, I've been doing operations for a couple of years, and I still have a TON TO LEARN about how to do this "SRE" job.
But along the way, I have learned a few ways to debug tricky problems, get the information I need from my colleagues, and get my job done. We're going to talk about
* how asking dumb questions is actually a superpower
* how you can read the source code to the Linux kernel when all else fails
* debugging tools that make you FEEL like a wizard
* and how understanding what your _organization_ needs can make you amazing
At the end, we'll have a better understanding of how you can get a lot of awesome stuff done even when you're not the highest level wizard on your team.
Each month, join us as we highlight and discuss hot topics ranging from the future of higher education to wearable technology, best productivity hacks and secrets to hiring top talent. Upload your SlideShares, and share your expertise with the world!
Not sure what to share on SlideShare?
SlideShares that inform, inspire and educate attract the most views. Beyond that, ideas for what you can upload are limitless. We’ve selected a few popular examples to get your creative juices flowing.
How to Make Awesome SlideShares: Tips & TricksSlideShare
Turbocharge your online presence with SlideShare. We provide the best tips and tricks for succeeding on SlideShare. Get ideas for what to upload, tips for designing your deck and more.
SlideShare is a global platform for sharing presentations, infographics, videos and documents. It has over 18 million pieces of professional content uploaded by experts like Eric Schmidt and Guy Kawasaki. The document provides tips for setting up an account on SlideShare, uploading content, optimizing it for searchability, and sharing it on social media to build an audience and reputation as a subject matter expert.
This document summarizes the following:
1) It introduces the monthly publication "International Tax News" which provides updates and analysis on international tax developments authored by PwC specialists.
2) It highlights several key international tax law changes and proposals in countries such as Cyprus, Brazil, Switzerland, the UK, Canada, Hong Kong, Italy and more.
3) It specifically outlines proposed changes in Cyprus regarding the introduction of a notional interest deduction on new corporate equity and proposals for tax neutral treatment of foreign exchange differences.
A Critical Evaluation of the OECD's BEPS ProjectRamon Tomazela
This document provides a critical analysis of the OECD's BEPS (base erosion and profit shifting) project from the perspective of an international tax law expert. It summarizes key actions and proposals from the BEPS project, and identifies challenges. Action 1 addresses taxing the digital economy, but determining which states can tax and allocating taxable profits will be difficult. Action 2 aims to prevent tax benefits from hybrid financial instruments and entities, but linking tax treatments across countries relies on debatable principles of international tax law. The BEPS project may be insufficient to fully address issues caused by economic changes and requires radical tax law reforms.
The document discusses several recent tax developments across Europe:
1) The European Commission ordered Ireland to recover up to €13 billion in back taxes from Apple, claiming Ireland's tax rulings with Apple constituted illegal state aid. This decision does not affect Ireland's overall tax system.
2) New rules were enacted in the Netherlands imposing country-by-country reporting requirements and transfer pricing documentation obligations on large multinational groups.
3) The Silicon Valley Tax Directors Group sent a letter to the Dutch government with suggestions to improve the Netherlands' business tax regime and maintain its competitiveness in attracting foreign investment. They expressed concerns about the EU's anti-tax avoidance directive and public country-by-country reporting proposals
The document discusses several recent tax developments across Europe:
1) The European Commission ordered Ireland to recover up to €13 billion in back taxes from Apple, claiming Ireland's tax rulings with Apple constituted illegal state aid. This decision does not affect Ireland's overall tax system.
2) New rules were enacted in the Netherlands imposing country-by-country reporting requirements and transfer pricing documentation obligations on large multinational groups.
3) The Silicon Valley Tax Directors Group sent a letter to the Dutch government with suggestions to improve the Netherlands' business tax regime and maintain its competitiveness in attracting foreign investment. They expressed concerns about the EU's anti-tax avoidance directive and public country-by-country reporting proposals
US desk quarterly newsletter - December 2016 editionVesko Petkov
This document summarizes tax law changes and initiatives across several European countries. It discusses proposed changes to dividend withholding tax rules and hybrid mismatch rules in the Netherlands. For Ireland, it outlines the new Knowledge Development Box tax regime. For Luxembourg, it discusses corporate tax rate reductions and increased transparency requirements around country-by-country reporting and transfer pricing rules. For Germany, it previews potential amendments to tax laws around real estate entities and losses. The UK section forecasts tax implications for multinationals from its upcoming autumn statement.
The document discusses recent changes to the Annual Tax on Enveloped Dwellings (ATED) in the UK. The ATED applies taxes to high-value residential properties owned by corporate entities and non-natural persons. Recent changes have lowered the threshold for properties subject to the tax and increased tax rates. This subjects more properties to the tax, including some held by property developers and letting businesses. Filing requirements and available reliefs are also discussed.
VIETNAM TAXATION – OUTLOOK ON THE EUROPEAN UNION VIETNAM FREE TRADE AGREEMENT...Dr. Oliver Massmann
The document discusses several issues with Vietnam's taxation system and opportunities presented by the EU-Vietnam Free Trade Agreement (EVFTA). It identifies inconsistencies between central government policies and local tax department practices, contradictory regulations, and complexity in VAT calculation and refund rules that create difficulties for businesses. Implementation of clearer rules and guidelines is needed to resolve tax payment issues, properly apply incentives, and avoid penalties from changing interpretations. The EVFTA is expected to boost investment and trade but also influence Vietnam to adopt more fixed and determined tax rules for greater certainty.
VIETNAM TAX ISSUES – OUTLOOK ON THE EUROPEAN UNION VIETNAM FREE TRADE AGREEME...Dr. Oliver Massmann
The document discusses several issues related to Vietnam's tax system and opportunities under the EU-Vietnam Free Trade Agreement (EVFTA). It notes inconsistencies in how local tax departments apply tax incentives for businesses and calls for clearer guidance. It also points out complexities for enterprises in complying with the declarations and incentives across different documents. Additionally, it raises concerns about discrimination in value-added tax refunds for businesses with output VAT at 5% compared to exporters. Overall, it advocates for simplifying regulations and ensuring fair and consistent treatment of businesses under Vietnam's tax system.
MEXICO’S 2014 TAX REFORM: A BRIEF REVIEW OF SOME OF ITS MOST RELEVANT ISSUESHogan Lovells BSTL
On 8 September 2013, the Mexican President
submitted to the Mexican Congress a bill
proposing a comprehensive tax reform.
Among other aspects, this bill proposed:
• the enactment of a new Income Tax Law;
• the suppression of the business flat rate tax
(‘IETU’) and tax on cash deposits (‘IDE’);
and
• significant amendments to the Value
Added Tax Law, Federal Tax Law and to
various excise taxes.
Permanent Establishment May Not Be So Permanent (Prepare for Change)Accounting_Whitepapers
The document summarizes the UK's new Diverted Profits Tax (DPT), which seeks to tax profits from UK economic activity that currently avoid UK corporate tax through arrangements deemed "contrived." The 25% DPT will apply to arrangements designed to avoid a UK permanent establishment or that create an "effective tax mismatch." Additionally, proposed changes to permanent establishment definitions in OECD's BEPS Action 7 may also expand the scope of countries' taxing rights. Multinational companies should review their structures and arrangements for potential DPT or BEPS Action 7 impacts and consider establishing a formal UK taxable presence to avoid the DPT.
The csll and the substantive scope of brazilian tax treatiesRamon Tomazela
This article considers aspects of the social contribution on net profits (contribuição social sobre o lucro
liquido, CSLL) in relation to the substantive scope of tax treaties concluded by Brazil and, inter alia, whether
the enactment of a domestic law dealing with the application of the CSLL involves a treaty override or simply a
legislative interpretation.
Global Indirect Tax Outlook - 2017 and BeyondDavid Duffy
What are the key global trends in indirect taxes?
"Global Indirect Tax Outlook - 2017 and Beyond" written by myself, Philippe Stephanny and Donald Hok has been now published in Bloomberg's July 2017 edition of "Tax Planning International".
Diverted Profits Tax (a) Google Tax: United Kingdom’s combat against tax evasionThangadurai Punithan
The government of the UK (United Kingdom) has enacted a measure – Diverted Profits Tax (‘DPT’) – in its Finance Act, 2015, to penalize the corporations who have diverted their profits elsewhere to dodge their tax payouts in UK.
This document provides an overview of base erosion and profit shifting (BEPS) and the OECD's BEPS Action Plan. It discusses how MNEs have engaged in tax planning to artificially shift profits to low/no tax locations. In response, the OECD published an Action Plan in 2013 to address BEPS in a comprehensive manner through 15 actions. The actions are structured around reinforcing substance requirements, aligning taxation with economic activity, and improving transparency. The document then summarizes some of the specific actions, including addressing tax challenges of the digital economy and neutralizing the effects of hybrid mismatches.
The document provides an overview of BEPS (Base Erosion and Profit Shifting) which refers to tax avoidance strategies used by multinational enterprises to artificially shift profits to low or no-tax jurisdictions. It summarizes the key actions and recommendations from the OECD's BEPS project to address this issue, including establishing new minimum standards around preventing treaty abuse, improving transparency through country-by-country reporting, and strengthening transfer pricing rules and controlled foreign company rules. It also discusses some of the changes made in India's tax regime to tackle BEPS concerns related to the digital economy, hybrid mismatches, interest deductions, and harmful tax practices.
The document summarizes tax issues in Vietnam discussed by the We Taxation and Transfer Pricing Sector Committee. It addresses five key areas: 1) VAT-related issues regarding VAT rates for export services and non-VAT clawbacks for failed oil and gas projects. 2) Restricted deductibility of advertising and promotional expenses. 3) Issues with tax treaty claims and treatment of capital transfers in real estate companies. 4) Foreign contractor withholding tax treatment related to warranties and distribution rights. 5) Simplifying documentation for foreign tax credits. Recommendations are provided for each area to improve tax regulations and create a more competitive investment environment.
Corporate Sustainability Due Diligence Directive (CSDDD or the EU Supply Chai...Dr. Oliver Massmann
Corporate Sustainability Due Diligence Directive (CSDDD or the EU Supply Chain Law): A Comprehensive Analysis and Review of its Implications on Vietnam-based Companies
Tributação e Economia Digital: OCDE, EU e BrasilRamon Tomazela
O documento anuncia um seminário sobre tributação e economia digital promovido pela Secretaria da Fazenda e Planejamento do Estado de São Paulo. O evento irá discutir propostas da OCDE, União Europeia e medidas de países sobre o tema, com foco no caso brasileiro. Especialistas irão debater soluções para tributar gigantes digitais de forma justa e evitar problemas como bi-tributação.
A competividade no mercado global e a migração para regimes territoriaisRamon Tomazela
i) A competição fiscal entre países e a mobilidade de capitais levam à tendência de adoção de regimes de tributação territorial, que isentam lucros estrangeiros. Isso atrai investimentos e reduz inversões de estruturas societárias para fins fiscais.
ii) Regimes universais de tributação prejudicam a competitividade de empresas em mercados globais e desestimulam a repatriação de lucros acumulados no exterior.
iii) Países adotam a territorialidade parcial para conter perdas de arrecadação devido à concorrência
A Convenção Multilateral da OCDE e a Ação 15 do Projeto BEPSRamon Tomazela
A União Europeia está preocupada com o impacto da inteligência artificial no mercado de trabalho. A Comissão Europeia está desenvolvendo novas diretrizes para garantir que a IA seja desenvolvida e implantada de forma ética e segura, protegendo os direitos dos trabalhadores. As novas diretrizes também visam promover a competitividade da UE e o desenvolvimento responsável da IA.
Territorial Tax Systems: Motivations and Key Considerations For Effective ChangeRamon Tomazela
In this article, the author examines why some countries are moving to territorial tax systems, suggesting that they will need
comprehensive sourcing rules and a strong transfer pricing regime to ensure the transition is an effective approach to the challenges posed by today’s global economy.
Preços de Transferência e Aplicações FinanceirasRamon Tomazela
Artigo a respeito aplicação das regras de preços de transferência para o controle de aplicações financeiras realizadas com partes vinculadas no exterior.
A Cláusula de Não Discriminação nos Acordos de BitributaçãoRamon Tomazela
A empresa anunciou um novo produto que combina hardware e software para fornecer uma solução completa para clientes. O produto oferece recursos avançados de inteligência artificial e aprendizado de máquina para ajudar os usuários a automatizar tarefas complexas. Analistas acreditam que o produto pode ser um sucesso comercial se for fácil de usar e entregar resultados precisos como prometido.
A Ação 3 do Projeto BEPS e o regime brasileiro de tributação em bases univers...Ramon Tomazela
O presente artigo aborda a Ação 3 do Projeto BEPS e o regime brasileiro de tributação em bases
universais na Lei nº 12.973/2014, destacando as aproximações e os distanciamentos existentes
entre o relatório de melhores práticas da OCDE e a legislação doméstica brasileira.
Curso de extensão e aperfeiçoamento em Direito Tributário Internacional - IBDTRamon Tomazela
O documento fornece informações sobre um curso de extensão e aperfeiçoamento em direito tributário internacional, incluindo: datas e horários das aulas, valor das inscrições, coordenador, corpo docente, conteúdo programático e público-alvo.
US Tax Reform: The Potential Tax Implications for Brazilian TaxpayersRamon Tomazela
In this article, the author analyses the main corporate tax reform proposals under discussion in the United States
and their potential implications for Brazilian taxpayers.
A Declaração País-a-País e a Ação 13 do Projeto BEPSRamon Tomazela
1. O documento discute a Declaração País-a-País instituída no Brasil pela Instrução Normativa RFB no 1.681/2016, com base na Ação 13 do Projeto BEPS da OCDE.
2. Argumenta-se que a Declaração País-a-País não poderia ter sido instituída por ato normativo infralegal, uma vez que exige informações sobre entidades no exterior, extrapolando a competência constitucional da administração tributária.
3. Analisa-se a Instrução Normativa RFB no 1.
Tax Sovereignty and Digital Economy in Post-BEPS TimesRamon Tomazela
This chapter discusses challenges that digital transactions pose to traditional concepts of tax sovereignty, especially as international tax regimes need to adapt to the new digital economy. It first discusses how the principle of territoriality and recognition of tax jurisdiction developed in international law. It then addresses how tax jurisdiction has expanded due to the development of e-commerce and new business models, demonstrating the process of reconfiguring the concept of tax sovereignty. Finally, it focuses on how the consumer market now stands out as the main connecting factor for taxing income derived from e-commerce, representing a new facet of tax sovereignty in a globalized world.
O controle de preços de transferência nas exportações de commodities e o méto...Ramon Tomazela
O presente artigo analisa diversas controvérsias envolvendo o método do preço sob cotação
na exportação, introduzido no ordenamento jurídico brasileiro pela Lei nº 12.715/2012, que deve ser
obrigatoriamente aplicado para o controle de preços de transferência nas operações de exportação de
commodities.
A restrição ao aproveitamento do ágio de rentabilidade futura nas operações e...Ramon Tomazela
Este artigo analisa a restrição introduzida pela Lei no 12.973/2014 à utilização fiscal do ágio de rentabilidade futura em reorganizações societárias entre empresas do mesmo grupo econômico. O artigo discute 1) como o ágio de rentabilidade futura é tratado pela Lei no 12.973/2014, 2) as regras contábeis para combinações de negócios, 3) o "ágio interno" na jurisprudência administrativa, 4) a validade da restrição completa ao uso do ágio em operações entre partes dependentes, e 5
O Imposto de Renda e as receitas de frete internacional - Ramon Tomazela e Pa...Ramon Tomazela
1. O documento analisa a incidência do Imposto de Renda sobre receitas de frete internacional sob a lei brasileira e acordos internacionais.
2. A lei brasileira e decretos antigos preveem isenção do imposto para empresas estrangeiras de transporte caso empresas brasileiras gozem do mesmo tratamento no país estrangeiro.
3. Leis posteriores estabeleceram alíquotas para empresas estrangeiras, mas isentaram empresas cujos países não tributam empresas brasileiras, em conformidade com acordos internacionais.
RTDA - pagamento de garantia nos acordos de bitributaçãoRamon Tomazela
A empresa de tecnologia anunciou um novo smartphone com câmera aprimorada, maior tela e melhor desempenho. O dispositivo também possui recursos adicionais de inteligência artificial e segurança de dados aprimorados. O lançamento do novo smartphone está programado para o final deste ano.
O desvirtuamento da teoria do propósito negocial:Ramon Tomazela
O documento apresenta um resumo da origem e evolução da teoria do propósito negocial no direito tributário norte-americano e brasileiro. Inicialmente, descreve o caso Gregory vs. Helvering de 1934, que estabeleceu os fundamentos iniciais da teoria com base na interpretação teleológica de uma regra tributária sobre reorganizações societárias. Posteriormente, explica como a teoria foi sendo desvirtuada ao longo do tempo em diferentes jurisdições, perdendo o seu lastro jurídico original. Por fim, argumenta que
O pagamento de juros sobre o capital próprio (JCP) será afetado pela Ação 2 d...Ramon Tomazela
1. O documento descreve uma revista de direito tributário brasileira que serve como repositório de jurisprudência de vários tribunais brasileiros. 2. Analisa a Ação 2 do Projeto BEPS da OCDE, que visa neutralizar os efeitos de planejamento tributário internacional com entidades e instrumentos financeiros híbridos. 3. Discute se o pagamento de Juros sobre Capital Próprio para acionistas não residentes pode ser afetado pela Ação 2 do BEPS, tanto sob a lei tributária brasileira quanto sob a perspectiva do país de
Genocide in International Criminal Law.pptxMasoudZamani13
Excited to share insights from my recent presentation on genocide! 💡 In light of ongoing debates, it's crucial to delve into the nuances of this grave crime.
Guide on the use of Artificial Intelligence-based tools by lawyers and law fi...Massimo Talia
This guide aims to provide information on how lawyers will be able to use the opportunities provided by AI tools and how such tools could help the business processes of small firms. Its objective is to provide lawyers with some background to understand what they can and cannot realistically expect from these products. This guide aims to give a reference point for small law practices in the EU
against which they can evaluate those classes of AI applications that are probably the most relevant for them.
Sangyun Lee, 'Why Korea's Merger Control Occasionally Fails: A Public Choice ...Sangyun Lee
Presentation slides for a session held on June 4, 2024, at Kyoto University. This presentation is based on the presenter’s recent paper, coauthored with Hwang Lee, Professor, Korea University, with the same title, published in the Journal of Business Administration & Law, Volume 34, No. 2 (April 2024). The paper, written in Korean, is available at <https://shorturl.at/GCWcI>.
Defending Weapons Offence Charges: Role of Mississauga Criminal Defence LawyersHarpreetSaini48
Discover how Mississauga criminal defence lawyers defend clients facing weapon offence charges with expert legal guidance and courtroom representation.
To know more visit: https://www.saini-law.com/
Lifting the Corporate Veil. Power Point Presentationseri bangash
"Lifting the Corporate Veil" is a legal concept that refers to the judicial act of disregarding the separate legal personality of a corporation or limited liability company (LLC). Normally, a corporation is considered a legal entity separate from its shareholders or members, meaning that the personal assets of shareholders or members are protected from the liabilities of the corporation. However, there are certain situations where courts may decide to "pierce" or "lift" the corporate veil, holding shareholders or members personally liable for the debts or actions of the corporation.
Here are some common scenarios in which courts might lift the corporate veil:
Fraud or Illegality: If shareholders or members use the corporate structure to perpetrate fraud, evade legal obligations, or engage in illegal activities, courts may disregard the corporate entity and hold those individuals personally liable.
Undercapitalization: If a corporation is formed with insufficient capital to conduct its intended business and meet its foreseeable liabilities, and this lack of capitalization results in harm to creditors or other parties, courts may lift the corporate veil to hold shareholders or members liable.
Failure to Observe Corporate Formalities: Corporations and LLCs are required to observe certain formalities, such as holding regular meetings, maintaining separate financial records, and avoiding commingling of personal and corporate assets. If these formalities are not observed and the corporate structure is used as a mere façade, courts may disregard the corporate entity.
Alter Ego: If there is such a unity of interest and ownership between the corporation and its shareholders or members that the separate personalities of the corporation and the individuals no longer exist, courts may treat the corporation as the alter ego of its owners and hold them personally liable.
Group Enterprises: In some cases, where multiple corporations are closely related or form part of a single economic unit, courts may pierce the corporate veil to achieve equity, particularly if one corporation's actions harm creditors or other stakeholders and the corporate structure is being used to shield culpable parties from liability.
Synopsis On Annual General Meeting/Extra Ordinary General Meeting With Ordinary And Special Businesses And Ordinary And Special Resolutions with Companies (Postal Ballot) Regulations, 2018
Matthew Professional CV experienced Government LiaisonMattGardner52
As an experienced Government Liaison, I have demonstrated expertise in Corporate Governance. My skill set includes senior-level management in Contract Management, Legal Support, and Diplomatic Relations. I have also gained proficiency as a Corporate Liaison, utilizing my strong background in accounting, finance, and legal, with a Bachelor's degree (B.A.) from California State University. My Administrative Skills further strengthen my ability to contribute to the growth and success of any organization.
This document briefly explains the June compliance calendar 2024 with income tax returns, PF, ESI, and important due dates, forms to be filled out, periods, and who should file them?.
सुप्रीम कोर्ट ने यह भी माना था कि मजिस्ट्रेट का यह कर्तव्य है कि वह सुनिश्चित करे कि अधिकारी पीएमएलए के तहत निर्धारित प्रक्रिया के साथ-साथ संवैधानिक सुरक्षा उपायों का भी उचित रूप से पालन करें।
What are the common challenges faced by women lawyers working in the legal pr...lawyersonia
The legal profession, which has historically been male-dominated, has experienced a significant increase in the number of women entering the field over the past few decades. Despite this progress, women lawyers continue to encounter various challenges as they strive for top positions.